Integrity: An important appeal from EPA union

We have received this very important and critical appeal for help from Dr. William Hirzy, Senior Vice-President of the National Treasury Employees Union Chapter 280, representing professional employees at U.S. Environmental Protection Agency Headquarters. The appeal pertains to a refusal by EPA Administrator Christine Todd Whitman to uphold the “EPA’s Principles of Scientific Integrity”, a set of principles which were won by this very union after many years of effort.

This appeal concerns us all. I can think of no other action more important to the cause of repudiating the practice of water fluoridation than the action of this Union (the Union which represents the professionals at EPA’s DC headquarters) in coming out publicly against water fluoridation.

Moreover, it is a lack of scientific integrity at the highest levels of the US regulatory apparatus (e.g. EPA, DHHS, CDC, FDA) which makes it so difficult to get this issue re-examined in the light of new evidence on both its lack of effectiveness and its serious threats to human health and the environment.

Unless we can get “scientitic integrity” established (or re-established?) as the cornerstone of policy making, we are doomed to have otherwise honest and decent employees become the pawns of rotten political agendas. Moreover, we all know to our cost that a “little” lack of integrity at the center goes a very long way to subvert the system all the way down the line. We are all too familiar with local and state government health and dental officials who repeat the dishonest analysis of the CDC on water fluoridation like mindless parrots.

…I hope all our readers will do what they can to send in letters to EPA Director Whitman and e-mails to their Senators and Conressmen to express shock at Whitman’s unwillingness to endorse and enforce the EPA’s “Principles of Scientific Integrity”. May I also suggest that folks outside the US consider writing to President Bush on this one . They might argue that if “integrity” is not seen to be at the heart of all US government policy, then it diminishes this country in the eyes of the world.

In addition to sending copies to Bill Hirzy , I would really appreciate copies at .

Thank you for your help on this urgent matter.

Paul Connett.

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Message from Dr. William Hirzy.

May 4, 2002

Dear Friends and Allies:

I am writing to ask for your help. On May 1, 2002, this union, which has tried to be of service to you by its ethical application of science to fluoride, malathion, indoor air quality and other issues, conducted an informational picket at EPA Headquarters. The picketing and leafleting was in connection with EPA’s “Science Forum,” an event staged to tout EPA’s use of quality science in its regulatory work.

The help we seek from you is to put pressure on EPA to start really using good science in its regulatory work: something that could, for example, lead to good-science based drinking water standards, indoor air quality measures and pesticide controls. These three examples cover a few of the cases in which you and the union have been allies in the struggle for public health protection.

The reason we did the May 1 action was because EPA refuses to take any steps to implement or enforce its Principles of Scientific Integrity (Principles) policy. The union was the driving force behind getting EPA to adopt the Principles as policy during the previous administration. EPA management grudgingly agreed to accept the union’s proposals for this policy in 1999. The Principles appear at the end of this message.

Here are the circumstances that prompted our action and this call for help.

The union filed a grievance on March 15 of this year over a manager telling an employee, “It’s your job to support my decisions, even if I say, 2 + 2 = 7.” We filed based on the fact that pressuring employees to craft spurious scientific cover to support a management decision is both illegal under a number of statutes and a violation of EPA’s Principles of Scientific Integrity.

The relief we sought in the grievance had two elements: 1) we asked for EPA Administrator Whitman to issue a statement that repudiates such illegal and unethical management pressure on staff and that re-states EPA’s Principles of Scientific Integrity; and 2) we asked for establishment of a work group to develop a plan to implement the Principles of Scientific Integrity, including a mechanism for resolving disputes that arise pursuant to the Principles.

The grievance was filed with the Deputy Administrator (number 2 person at EPA), with copies to three Assistant Administrators and to Labor Relations. No one in management made any reply to the grievance until 23 days past the date when a reply was due, March 30.

On April 3, EPA announced its “Science Forum,” — open to the public, Congressional staff and media invited — to be held May 1 and 2, at which EPA would tell how it uses quality science to develop its policies and regulations. The union executive board decided upon a presence for the union at this gathering. When the reply to our grievance finally came, on April 22, it denied our request for relief and stated EPA’s position that we could not file grievances over the Principles of Scientific Integrity, in essence, EPA said the Principles are a pretty window dressing with no practical meaning and would not be enforced.

On May 1, we made known to those attending the meeting, through our signs and leaflet, how the union feels about scientific integrity, how science and policy are really integrated at EPA, and how senior EPA officials tolerate management pressure on staff to support policy decisions with after-the-fact “science” of the 2 + 2 = 7 variety.

The union was founded in the early 1980’s for one specific purpose: to ensure that EPA staff professionals have as ethical a work environment as possible in which to pursue their professions in protecting public health and the environment.

This administration’s leaders’ disdain for that concept, as displayed by their failure to respond timely to our grievance, and then to deny any relief, puts them at odds with those of us who will continue to insist that our work be done to the highest professional standards.

What we need from you is communication from you to your two Senators and your Representative in the House about this matter. We also need you to communicate with EPA Administrator Christine Todd Whitman and Assistant Administrator Morris X. Winn, to whom the head of EPA labor relations reports. Friends outside the U.S. can write directly to Ms. Whitman and Mr. Winn at the address below, or think of other ways to help.

Just as our work has been synergistic with yours in your communities, your aiding us in this way will help us to force EPA to halt unethical pressure on employees and to fully implement the Principles of Scientific Integrity at the Agency.

Messages to Congress: We suggest that you ask your three Congressional representatives to inquire on your behalf why Ms. Whitman refuses to repudiate “2+2=7” orders by managers, and why she refuses to warn managers that they will be disciplined if they put unethical or illegal pressure on employees, and why she refuses fully to implement or enforce EPAís policy on Scientific Integrity. Ask your representatives to send you copies of EPA replies to their inquiries. If you are not satisfied with the response, we suggest that you write again. We would appreciate receiving copies of any responses that you get.

Messages to EPA: We suggest that you ask Ms. Whitman why [in the] EPA some managers ignore the Principles of Scientific Integrity like the plague. Ask why Ms. Whitman refuses to repudiate “2+2=7” orders from management and refuses to warn managers of the disciplinary consequences that will flow if such orders are imposed on EPA staff. Ask why she refuses to honor, implement and enforce EPA’s own Principles of Scientific Integrity, and why she refuses to work out a method for resolving disputes concerning the Principles. You may want to raise other questions as well.

We suggest old fashioned letters to both Congress and EPA. At EPA, Ms. Whitman has no e-mail address accessible to the public, and Mr. Winn may set his e-mail system to automatically delete messages from citizens, especially if the title line mentions the union or scientific integrity. Your representatives in Congress, however, will not ignore you (even if you use e-mail), and EPA cannot ignore inquiries from Congress. The pressure you bring to bear on EPA through your Senators and Representative will be supremely valuable.

EPA’s mailing address is: U.S. EPA, 1300 Pennsylvania Ave., N.W., Washington, D.C. 20460. If you wish to e-mail Mr. Winn anyway, his e-mail address is: You may wish to send a copy of any e-mail to Mr. Winn also to this address: . Mr. Sharfstein is the head of labor relations at EPA.

If we in this union have been of any help to you and/or your community, I plead with you to help us now. Please spread this word among all your friends, acquaintances and allies in the struggle for good health and a clean environment. The union needs you now. Together, we can do great things for the environment and public health by bringing Scientific Integrity to life within EPA.

Integrity must be the cornerstone of this Agency’s work. EPA’s Principles of Scientific Integrity, which appear at the end of this statement, were adopted by the previous administration. I want every EPA employee to understand clearly that this administration fully subscribes to them and intends to enforce them. This is not a partisan matter.

It has come to my attention that on occasion managers pressure staff to support management decisions that require science input regardless of a decisionís scientific merit, even to the point of requiring staff to assert that “two plus two equals seven.” I want it plainly understood that such action by managers will not be tolerated on my watch.

In addition to the fact that such pressure is illegal, our management responsibility as the President’s surrogates within the halls of EPA is to faithfully execute the laws passed by Congress and entrusted to our administration. Certain laws permit managers to make decisions that are based on factors other than scientific merit, and such non-science-based decisions can be done ethically and lawfully. But any manager who is tempted to pressure staff to fabricate spurious scientific cover for a decision that must be based on science should look for employment elsewhere.

Any manager who does less than faithful execution of the law will be fired. Any manager who knowingly violates the Principles of Scientific Integrity will be disciplined.

All of us who work at EPA, managers and staff alike, must adhere to the Principles of Scientific Integrity, which simply stated, instruct us to not to lie, cheat or steal, to understand the law as it applies to our work, and to do our best. If any employee has a question about application of the Principles of Scientific Integrity to his or her work, he or she should contact the Deputy Administrator.

Principles of Scientific Integrity

It is essential that EPA’s scientific and technical activities be of the highest quality and credibility if EPA is to carry out its responsibilities to protect human health and the environment. Honesty and integrity in its activities and decision-making processes are vital if the American public is to have trust and confidence in EPA’s decisions. EPA adheres to these Principles of Scientific Integrity.

EPA employees, whatever their grade, job or duties, must:

* Ensure that their work is of the highest integrity – this means that the work must be performed objectively and without predetermined outcomes using the most appropriate techniques. Employees are responsible and accountable for the integrity and validity of their own work. Fabrication or falsification of work results are direct assaults on the integrity of EPA and will not be tolerated.

* Represent their own work fairly and accurately. When representing the work of others, employees must seek to understand the results and the implications of this work and also represent it fairly and accurately.

* Respect and acknowledge the intellectual contributions of others in representing their work to the public or in published writings such as journal articles or technical reports. To do otherwise is plagiarism.

* Employees should also refrain from taking credit for work with which they were not materially involved.

* Avoid financial conflicts of interest and ensure impartiality in the performance of their duties by respecting and adhering to the principles of ethical conduct and implementing standards contained in Standards of Ethical Conduct for Employees of the Executive Branch and in supplemental agency regulations.

* Be cognizant of and understand the specific, programmatic statutes that guide the employee’s work.

* Accept the affirmative responsibility to report any breach of these principles.

* Welcome differing views and opinions on scientific and technical matters as a legitimate and necessary part of the process to provide the best possible information to regulatory and policy decision-makers.

* Adherence by all EPA employees to these principles will assure the American people that they can have confidence and trust in EPA’s work and in its decisions.